Dubai vs Saudi Arabia: where to buy property in 2026 and how the rules compare

Dubai vs Saudi Arabia: the key differences at a glance

Figures come from official UAE and Saudi sources, and where a point rests only on law-firm or consultant summaries, we say so. The sources are listed at the end of the guide.

• Who can buy. Dubai: foreigners may hold freehold without time limit, or usufruct or leasehold of up to 99 years, in designated areas. Saudi Arabia: non-Saudis may own in zones approved by the Council of Ministers, and a legal resident may own one home outside those zones, except in Makkah and Madinah.
• Makkah and Madinah. A non-Saudi individual may own property there only if they are Muslim, and only within approved zones.
• Transaction costs. Dubai: a Dubai Land Department (DLD) registration fee of 4% of the property value. Saudi Arabia: a 5% Real Estate Transaction Tax (RETT) plus, on transactions involving non-Saudis in Riyadh, Jeddah, Makkah and Madinah, a REGA fee that advisers report at 2%.
• Residency. Dubai: an investor Golden Visa for property worth at least AED 2,000,000. Saudi Arabia: Premium Residency for property owners from SAR 4,000,000 with no mortgage. Both are separate applications with conditions.
• Income tax. The UAE has no personal income tax. According to PwC, Saudi Arabia does not tax employment income; how a foreign individual's rental income is taxed has not been officially confirmed.
• Market maturity. Dubai's freehold regime for foreigners has been set in law since 2006; Saudi Arabia's current regime has applied since 22 January 2026.

Who can buy property in Dubai and in Saudi Arabia

In Dubai, property ownership is by default reserved for UAE and GCC nationals. Article 4 of Dubai Law No. 7 of 2006 lets non-UAE nationals, with the Ruler's approval, hold freehold without time limit, or usufruct or leasehold of up to 99 years, in areas the Ruler designates. The original list under Regulation No. 3 of 2006 named 23 areas, including Dubai Marina, Palm Jumeirah and Emirates Hills; it has since been extended, so check the status of a given address with the DLD.

In Saudi Arabia, the Law of Real Estate Ownership and Investment by Non-Saudis has applied since 22 January 2026, replacing the 2000 law. Non-Saudi individuals, both residents and non-residents, as well as foreign companies, may own property in zones approved by the Council of Ministers. Each zone sets the types of rights, the maximum foreign ownership shares and the usufruct terms.

In Riyadh, Jeddah, Makkah and Madinah, ownership is, as a rule, possible only inside the zones listed in the Geographic Zones Document, and the zone map is published on the government's Saudi Properties portal. Whether you can buy in Jeddah is therefore a question about a specific address, not the city. Official sources describe the rules for the rest of the country inconsistently, so those also need checking property by property.

Legal residents get one extra option: they may own a single residential property outside the approved zones, except in Makkah and Madinah. The rule does not let non-residents buy outside the zones.

The procedure differs too. A non-resident first obtains a Saudi digital identity through a Saudi mission abroad and then applies on the Saudi Properties portal. According to law-firm summaries, a Saudi bank account and a Saudi phone number are also required. Ownership arises only on registration with the Real Estate Registry: a reservation, contract or payment does not replace it.

Makkah and Madinah: ownership for Muslims only

If you are looking for a home near the Grand Mosque in Makkah or the Prophet's Mosque in Madinah, the Dubai comparison no longer applies: this is a purpose that only Saudi Arabia can serve, and it comes with stricter rules.

A non-Saudi individual may own property in Makkah and Madinah only if they are Muslim, whether they live in the Kingdom or abroad, and only within approved zones. The resident's one-home exception does not apply in these two cities. How a buyer's faith is verified should be confirmed with a Saudi lawyer before any reservation.

Transaction costs: the DLD fee in Dubai vs RETT and the REGA fee in Saudi Arabia

In Dubai, the main mandatory cost is the Dubai Land Department fee for registering a sale: 4% of the property value. Who pays which share depends on the type of transaction and the contract, and DLD pages describe it differently, so confirm the split with the DLD before signing.

In Saudi Arabia, property transactions are subject to the Real Estate Transaction Tax (RETT) at 5% of the price unless an exemption applies, whatever the condition or use of the property. The seller is legally liable, but the buyer is jointly liable if the tax goes unpaid, is understated or is paid late because of the buyer. For off-plan units, RETT is due no later than the notarised transfer of title. Property sales themselves are exempt from VAT. The first-home relief, under which the state covers RETT on up to SAR 1,000,000, applies to Saudi citizens only.

Transactions involving non-Saudis also attract a REGA fee. Article 9 of the ownership law imposes it at up to 5% of the value, without prejudice to other taxes and fees, so it does not replace RETT. According to Deloitte and Greenberg Traurig, the implementing regulations set it at 2% for property in Riyadh, Jeddah, Makkah and Madinah. Which party bears it is not officially settled, so budget for it and fix the split in the contract.

Comparing the percentages head to head is misleading. In Saudi Arabia the seller remains legally liable for RETT (the buyer jointly in the cases above), and a contract can shift only the cost, not that liability. In Dubai, the split of the DLD fee depends on the transaction type and the contract. Beyond taxes and fees, budget for any broker's commission, fit-out, furniture, service charges and management. Our guide to Saudi property taxes and buying costs covers the Saudi side in detail.

Residency through property: Dubai Golden Visa vs Saudi Premium Residency

In neither Dubai nor Saudi Arabia does buying property by itself grant residency. Both have separate programmes with their own thresholds and conditions, and each requires its own application.

In Dubai, an investor may apply for a Golden Visa when they own property with a purchase value of at least AED 2,000,000 at the time of purchase. The DLD page requires the property to be wholly owned by the applicant and registered in their name, while GDRFA says that for a share in jointly owned property the applicant's share must be worth at least AED 2,000,000, so confirm the rules for joint ownership with both when you apply. The property may be mortgaged if the bank issues a no-objection letter; according to the DLD service description, the letter must show at least AED 2,000,000 already paid. According to GDRFA, a lien is placed on the property and it cannot be disposed of while the residency is in force; the DLD adds that the applicant must be in the UAE. Official portals state the visa's duration differently, so check it with the DLD and GDRFA when you apply. The DLD and GDRFA pages do not say whether an off-plan unit qualifies.

Saudi Arabia offers Premium Residency for real estate owners. According to the Premium Residency Center, Category 1 covers a completed residential property worth at least SAR 4,000,000, owned or held in usufruct and free of any mortgage; land does not qualify. Category 2 covers one off-plan residential unit worth at least SAR 4,000,000, with at least SAR 1,000,000 or 10% of the price paid, whichever is higher, a REGA-approved developer, no mortgage and transfer of title within five years. The one-off fee is SAR 4,000. The residency lasts as long as the ownership (for Category 2, as long as the purchase contract) and lets the holder live in the Kingdom with family, work and own property. The Center states that all conditions may change.

Article 6 of the Saudi ownership law states that owning property confers no rights or privileges beyond those of a holder of a right in rem. Residency through property is therefore a separate matter under the Premium Residency law, which Article 5 of the ownership law expressly leaves unaffected. If residency is your main goal, check the programme's conditions first and choose a property that meets them second.

Income tax on property: what is confirmed for the UAE and Saudi Arabia

The UAE does not levy personal income tax, as the country's official government portal confirms.

According to PwC Worldwide Tax Summaries, Saudi Arabia does not tax individuals' employment income. Non-employment income, however, can be taxed as business income, and Saudi-source income of non-residents through withholding tax. We could not officially confirm how a foreign individual's rental income from a Saudi apartment is taxed, so ask a tax adviser before you buy. Residential rent in Saudi Arabia is exempt from VAT, which is not the same as being free of income tax.

Wherever you buy, your country of tax residence may tax the rent. Russian tax residents, for example, pay personal income tax in Russia on all income, including rent received abroad.

Market maturity, off-plan rules and financing in Dubai and Saudi Arabia

Dubai's freehold regime for foreigners has been set in law since 2006, so its rules are long established. That does not make Dubai the right choice for every buyer, but the transaction process there is well known.

Saudi Arabia's current regime has applied since 22 January 2026, but the Saudi Properties portal has accepted applications under it only since 23 June 2026. According to law-firm summaries, the Council of Ministers approved the implementing regulations and the geographic zones on that same day. Some details, such as ownership shares, deadlines and procedural penalties, are still known mainly from adviser summaries, so confirm them with a Saudi lawyer.

Off-plan sales in Saudi Arabia fall under a separate law in force since 4 April 2024. The project must hold a REGA licence on the Wafi platform, buyers' payments go into a dedicated project escrow account at a licensed bank, and the developer draws funds on requests approved by an engineering consultant and an auditor. Escrow governs how the money is used, but it is not an unconditional guarantee of completion or refund. This guide does not cover Dubai's off-plan rules; check them with the DLD.

Treat financing with care in both markets. A Dubai Golden Visa property may be mortgaged if, according to the DLD service description, the bank's letter shows at least AED 2,000,000 already paid, whereas a Saudi Premium Residency property must be mortgage-free. We found no official rule entitling foreign buyers to a mortgage in Saudi Arabia, and the SAMA rulebook limits real estate financing in Makkah and Madinah to Saudi nationals (whether that rule still applies under the new law should be checked with the bank), so do not count on a mortgage in advance.

Whether Saudi Arabia becomes "the next Dubai" is not a question facts can answer: it is a marketing metaphor, not a price forecast. Compare the rules in force instead.

Should you buy property in Dubai or Saudi Arabia? How to decide

It is easier to decide by working through four questions than by comparing the two countries in general.

1. Purpose. A home near the Haram for a Muslim buyer means Makkah or Madinah only. If you need residency, compare the Golden Visa and Premium Residency conditions rather than apartment prices. If you plan to let the property, allow for tax in your home country and management costs; neither market offers guaranteed income.
2. Budget. Add the 4% DLD fee in Dubai, or in Saudi Arabia the 5% RETT (the seller is legally liable; check the contract for who bears the cost) and the REGA fee in the four cities (reported as 2%; fix in the contract who pays it), plus commission, fit-out and running costs. The residency thresholds are AED 2,000,000 in Dubai and SAR 4,000,000 in Saudi Arabia.
3. Timeline. Wafi requires the contract for a Saudi off-plan unit to set the handover date to the day, and the regulations require compensation for developer-caused delay, but timelines can slip. Ownership exists only once it is registered. For Premium Residency Category 2, title must transfer within five years.
4. Documents. To buy in Saudi Arabia, a non-resident needs a Saudi digital identity and, according to law-firm summaries, a Saudi bank account and a local phone number. Check the property's address against the Saudi Properties zone map, and plan the payment route from your country with a specific bank in advance.

If Saudi Arabia stays on your list, browse the catalogue: Yarmax works with developers' properties in Jeddah, Riyadh, Al Khobar and Makkah (in Makkah, a non-Saudi individual may buy only if they are Muslim). Whether a foreign buyer can purchase a given property is checked against its address before any reservation; a listing in the catalogue does not confirm it. Our buying guide walks through the steps, and the taxes guide covers the costs.

If long-established rules matter more to you, or the Golden Visa conditions suit you, it makes sense to look at Dubai with an agency that works there. We sell property only in Saudi Arabia.

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